P01 SOW-Dole CoE-UT Medicine STX Research.doc

Section I STATEMENT OF WORK

1. DESCRIPTION OF SERVICES

The VA South Texas Veterans Health Care System (STVHCS) requires expert research services from their educational affiliate University of Texas Health Science Center at San Antonio, School of Medicine, Division of Hospital Medicine (UT Health-HospMed) 7703 Floyd Curl Dr, San Antonio, TX 78229 in support of multiple VA-funded research projects. These services include Co-Principal Investigator; Co-Investigator; Research Associate I, II, III, IV; Project Management; Research Coordinator; Database Programming; Data Analysis and Statistical Support; Conference Travel; Graphic and Printing Services; Publication Services; Training; and Participant Incentives. UT Health-HospMed will provide subject matter expertise; technical skill and knowledge; and academic, clinical and research capabilities to provide the below-detailed services and deliverables.

The objective of this contract is to obtain efficient and effective support for the writing of grant submissions for health services research studies and the execution of those studies to support the STVHCS RESEARCH SERVICE in its above stated mission and goals. Contractor employees shall not be construed as government employees for any service required by the terms of this contract. Examples of research projects the contractor will be required to investigate and research under the terms of this contract include research projects from Health Services Research and Development (HSR&D), Clinical Services Research and Development (CSR&D), Rehabilitation Research and Development (RR&D), Office of Rural Health (ORH), Quality Enhancement Research Initiative (QUERI) and other Veteran Affairs funded research.

2. PROJECT SPECIFIC INFORMATION

Specific details regarding Scope of Work issued or any combination of services stated in the Scope of Work can be combined. Any work requested will be initiated by the contractor through strict adherence to the VA approved protocols detailed in the Scope of Work and IRB protocol specific to the research projects associated with the request.

The contract includes Co-Investigator I, II, III; Research Scientist; Research Study/Project Coordinator; Research Associate I, II, III, IV; Publication Services; Graphic and Printing Services; Training; and Participant Incentives; Conference Travel; all listed below.

3. PERIOD OF PERFORMANCE

This contract is effective date of award of 10/01/2022 to 09/30/2023. Each order issued against this contract shall have a separate Period of Performance. The performance period will be based on pricing located in the schedule prior to the issuance of the Service Requirement Order/Purchase Order.

4. PLACE OF PERFORMANCE

Services will be rendered at VA South Texas Veterans Health Care System (STVHCS) San Antonio and/or designated Research project performance site/s as approved on the Protocol by the Internal Review Board (IRB).

5. SERVICES

Co-Investigator I, II; Research Scientist; Research Study/Project Coordinator; Research Associate I, II, III, IV; Publication Services; Graphic and Printing Services; Training; and Participant Incentives; Conference Travel.

6. Co-Investigator

Individual may be assigned as Co-Principal Investigator or Co-Investigator. Co-Principal Investigators in this contract are key personnel who have responsibilities like that of a Principal Investigator (PI) on research projects. While the PI has ultimate responsibility for the conduct of a research project, the Co-PI is also obligated to ensure the project is conducted in compliance with applicable laws and regulations and institutional policy governing the conduct of sponsored research. The Co-PI will have health services research expertise in the areas of community-based participatory research, chronic disease prevention or management, health disparities, health care delivery, quality of care, implementation science, complexity science, translational science, health promotion, and/or health systems. As Co-Investigator individuals provided for this contract shall be closely involved in the conduct of work; mentoring in health services research on topics of research methodology, survey development, health care utilization, health care quality, health care delivery, pharmacology, medication adherence, advanced statistical analysis techniques in biostatistics, and in other areas related to health services research as needed.

7. TASKS AND ASSOCIATED DELIVERABLES

· Together with PI deliver the work required within scope, schedule, and budget

· Develop with the PI the overall strategies for developing project goals and timelines

· Participate in and facilitate meetings with project staff, participants, and funders

· Assure proper practices and techniques

· Instruct, train, and mentor group members and support staff

· Utilize effective written and oral communication

· May assist with response to RFPs (request for proposals) and lead interviews

· May have supervisory responsibilities for group members and support staff including hiring, promoting, terminations, performance reviews, and training

· provide advanced statistical analysis

· provide functional subject matter expertise in health services research

· provide expertise in research methodologies and measures

8. Research Scientist

The individuals provided for this contract will participate in the design of complex research studies by working directly under the supervision of the Principal Investigator (PI) to carry out the development of grants and research related to the study. Plan and develop requirements with respect to various research studies including resource allocation and staffing required in accomplishing the study tasks. Perform any of the tasks necessary to complete research study include reviews of medical writing of study protocols, statistical analysis, progress notes, and data collection in clinic/hospital settings, ethnographic observations in clinic/hospital settings, conduct of semi-structured interviews of clinic/hospital staff and/or patients, distribution, and collection of surveys. Participate in journal development and writings for submission to professional publications and journals.

9. TASKS AND ASSOCIATED DELIVERABLES

· As assigned by the PI, deliver the work required within scope, schedule, and budget

· Develop with the PI the overall research strategies, goals, and timelines

· Participate and facilitate meetings with project staff

· Assure scientific soundness of research practices and techniques

· Provide scientific insight as related to the assigned research project/s.

· Utilize effective written and oral communication

· Participate in the development of new proposal in response to RFPs (request for proposals)

· provide advanced statistical analysis

· provide functional subject matter expertise in health services or clinical research

· provide expertise in research methodologies and measures

10. Research Study/Project Coordinator Personnel provided under this contract will coordinate complex research studies working directly under the supervision of the Principal Investigator. The research coordinate will be responsible for carrying out all tasks related to the study and supervising other staff who provide services for the study. Responsibilities will include managing IRB issues; oversee and participate in data collection activities in clinic/hospital/community settings including ethnographic observations, semi-structured and structured interviews, distributing and collecting surveys, conducting focus groups, facilitating staff meetings to improve the program/project functioning, and supervising others who perform such services.

11. TASKS AND ASSOCIATED DELIVERABLES

· Write, submit, and manage IRB applications and continuing renewals.

· Schedule and attend project meetings and

· Determine with the Principal Investigator project requirements

· Establish with the Principal Investigator the preliminary project schedules (Gantt charts) and modify as needed.

· Prepare project organization and communication charts

· Track the progress and quality of work being performed by other team members

· Use project scheduling and control tools to monitor projects plans, work hours, budgets, and expenditures

· Effectively and accurately communicate relevant project information to the Principal Investigator and project team

· Resolves project operational problems including identifying work process improvements.

· Design with Principal Investigator and manage data collection protocols

· Design with Principal Investigator and manage data quality assurance protocols

· Perform literature searches and library research

· Participate in the development of conference submissions and presentations and manuscripts for publication.

12. Research Associate I, II, III, IV The individuals provided for in this contract will perform a variety of tasks including setting up and maintaining study records; maintaining correspondence and study related materials; screening, evaluating, recruiting and consenting study participants; collecting data via structured and semi-structured in-person, mail and telephone surveys at baseline and scheduled follow-up time points; collecting data via electronic medical record review; conducting focus groups; preparing of study manuscripts and posters; preparing follow-up project proposals and reports for study funding agencies; overseeing data entry, quality control, and data management of study data; and designing databases for entry of study data. All services will be performed in accordance with protocol, privacy requirements and human subjects research regulations.

13. TASKS AND ASSOCIATED DELIVERABLES

· Identify, screen, recruit, and consent participants for studies

· Schedule participant appointments and site visits using MS Outlook and study-specific databases

· Conduct structured surveys with research participants over the phone, mail, and in person

· Record notes during visit interviews using an audio recorder; transcribe notes concurrent with the conduct of each interview; and complete transcription of the notes post-interview referring to the recording made during the interview.

· Assist in preparation of various tables and graphs summarizing qualitative and quantitative findings of the studies using MS Excel, Word, SPSS and SAS.

· Write sections of scientific manuscripts/abstracts and projects based on an outline provided by the study team, prepare manuscript/abstract tables and figures, and schedule meetings with each manuscript’s writing team as needed, and write submission cover letters.

· Complete and maintain all mandatory VA research trainings, including but not limited to, human subjects, data security, and privacy trainings, and ensure that these trainings are current in accordance with VA policy.

14. Publication Services

Publication costs for scientific articles that are published in open-access journals that do not have subscription charges.

15. Graphic and Printing Services:

This item in the contract includes the printing of posters for display at professional and/or scientific meetings. Size may vary slightly by conference, but typically must be of sufficient size for presentation on a display board approximately 4’H x 6’W. Exact specifications will be provided with each request. This also includes the creation of camera ready figures and tables for articles as required by scientific journals. Exact specifications will be provided with each request. Photography services may also be required and includes provisions for electric copies of photographs of contractor employees for display on the STVHCS Research Service website, staff bulletin board, and newsletter.

16. Training

This item in the contract is for the provision of registration or conference costs for technical training or upgrading of expertise in use of software for data management and/or statistical analysis. Training must be provided at local or regional conferences and provide workshops or tutorials that are skills-based or that provide hands-on demonstrations.

17. Participant Incentives STVHCS often conducts research where there is a requirement to obtain participation and/or collect information from participants. These participants may include any individual necessary for the research being conducted, i.e., external individuals. Researchers frequently find it necessary to offer incentives to obtain sufficient participation. No method for obtaining these incentives is available through STVHCS currently.

18. Conference Travel Personnel assigned to this contract will have the opportunity to present research at conferences and annual meetings to which they have been invited to attend. All travel must be approved by the COR. Travel expenses and reimbursement must follow GSA government approved travel rates not to exceed established per diem rates, airfare, mileage etc. VA ORD travel policy related to VA Research Appropriations must be followed and monitored by the COR.

19. DELIVERABLES AND PERFORMANCE STANDARDS

Throughout the course of the contract, UT Health-HospMed employees will be required to provide the following deliverables:

· Study databases that can be used to accurately capture study data, produce data management reports, and export data in a format suitable for analysis in SAS and SPSS software.

· Research proposals suitable for submission to appropriate funding agencies, such as VA HSR&D. Project proposals must be prepared in time to meet submission deadlines of each funding agency.

· Scientific papers suitable for peer-reviewed publication.

· Abstracts suitable for peer-reviewed conference presentations. Abstracts must be prepared in time to meet submission deadlines of each conference.

· Administer surveys, perform interviews, distribute incentives to research participants

· Transcribe all audio recorded interviews and focus groups

Throughout the course of the contract, employees of UT Health-HospMed will be required to meet the following performance standards:

· Work with the Project Manager under the overall direction of the Principal Investigator in the execution of all studies, including data collection, entry and coding, interview scheduling, and report preparation.

· Thoroughly and accurately prepare paperwork associated with all local IRB reviews to be reviewed by the Project Manager and Principal Investigator

· Promptly schedule study visits and telephone appointments.

· Accurately record and transcribe notes during participant surveys, interviews, and focus groups

· Assist as needed in preparation of various tables and graphs summarizing qualitative and quantitative findings of the studies production to be reviewed by Research Investigator.

· Perform other duties in accordance with the approved Statements of Work.

· Report any issues to the COR.

· Maintain all VA security and Privacy Requirements

20. DATA ACCESS, COLLECTION, AND STORAGE

Standard IRB-approved and HIPAA compliant measures will be used to maintain patient and provider confidentiality, privacy, and data security that adhere to the standards of the VA privacy officer, Information Security Officer, and Chief Information Officer. Where required by the IRB, contracted personnel must provide all study subjects with a HIPAA compliant, IRB-approved consent form that they will read and sign. When focus groups and interviews will be audio-taped, contract personnel must provide participants with a HIPAA compliant, IRB-approved consent form (10-3203) to sign. All patient and provider protected health information data collected via interviews, focus groups, surveys, and measurements must be entered into VA encrypted, password-protected computerized databases that will be constructed under the consultation of our database managers and maintained on the VA-owned servers behind the VA firewall. All paper data must be kept in locked, fire-proof file cabinets dedicated to the studies that are kept in locked offices at South Texas Veterans Health Care System (STVHCS). Only IRB- approved study personnel will have access to the data. Contracted personnel must not share data outside of the VA network. Portable storage devices used by contracted personnel will be supplied by the VA and protected by FIPS 140-2 certified encryption software. Portable electronic media devices used by contracted personnel must be secured under lock and key on VA property when not in the immediate vicinity of the responsible individual. All electronic data must reside on VA-owned computers and on VA-owned servers on the VA network behind the firewall. Backup of data must reside on a VA server. ‘VINCI’ the VA Informatics and Computing Infrastructure can also be used for data analysis and storage. From the VINCI website, http://vaww.vinci.med.va.gov/vincicentral/Overview.html ; “VINCI is a partnership between the VA Office of Information Technology (OI&T) and the Veterans’ Health Administration Office of Research and Development (VHA ORD). VINCI provides the storage and server technologies to securely host suites of databases integrated from select national data. These servers reside at the Austin Information Technology Center (AITC), located in Austin, Texas. To ensure the protection of Veterans data, VINCI maintains compliance with the guidelines set forth by Veterans Health Administration (VHA) Handbook 1200.12, Use of Data and Data Repositories in VHA Research and all other applicable VA and VHA policies and regulations. In addition, VINCI has undergone all security certification activities in support of obtaining an Authorization to Operate (ATO). Access to VINCI resources will be approved in accordance with the requirements of National Data Systems (NDS), VHA Handbook 1200.12, Use of Data and Data Repositories in VHA Research, and all other applicable VA and VHA policies and regulations. Researchers and Operations staff will access the data along with the tools for analysis and reporting in the secure, virtual working environment through a certified VHA network computer using the VA INTRANET (NOTE: VINCI is not accessible through the INTERNET).”

21. DATA SECURITY (AS PER VA HANDBOOK 6500.6, CONTRACT SECURITY, APPENDIX C)

Section II VA INFORMATION AND INFORMATION SYSTEM SECURITY/PRIVACY LANGUAGE FOR INCLUSION INTO CONTRACTS, AS APPROPRIATE

1. GENERAL

Contractors, contractor personnel, subcontractors, and subcontractor personnel shall be subject to the same Federal laws, regulations, standards, and VA Directives and Handbooks as VA and VA personnel regarding information and information system security.

2. ACCESS TO VA INFORMATION AND VA INFORMATION SYSTEMS

a. A contractor/subcontractor shall request logical (technical) or physical access to VA information and VA information systems for their employees, subcontractors, and affiliates only to the extent necessary to perform the services specified in the contract, agreement, or Service Requirement Order/Purchase Order.

b. All contractors, subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures.

c. Contract personnel who require access to national security programs must have a valid security clearance. National Industrial Security Program (NISP) was established by Executive Order 12829 to ensure that cleared U.S. defense industry contract personnel safeguard the classified information in their possession while performing work on contracts, programs, bids, or research and development efforts. The Department of Veterans Affairs does not have a Memorandum of Agreement with Defense Security Service (DSS). Verification of a Security Clearance must be processed through the Special Security Officer located in the Planning and National Security Service within the Office of Operations, Security, and Preparedness.

d. Custom software development and outsourced operations must be in the U.S. to the maximum extent practical. If such services are proposed to be performed abroad and are not disallowed by other VA policy or mandates, the contractor/subcontractor must state where all non-U.S. services are provided and detail a security plan, deemed to be acceptable by VA, specifically to address mitigation of the resulting problems of communication, control, data protection, and so forth. Location within the U.S. may be an evaluation factor.

e. The contractor or subcontractor must notify the Contracting Officer immediately when an employee working on a VA system or with access to VA information is reassigned or leaves the contractor or subcontractor’s employ. The Contracting Officer must also be notified immediately by the contractor or subcontractor prior to an unfriendly termination.

3. VA INFORMATION CUSTODIAL LANGUAGE

a. Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data - General, FAR 52.227-14(d) (1).

b. VA information should not be co-mingled, if possible, with any other data on the contractors/subcontractor’s information systems or media storage systems to ensure VA requirements related to data protection and media sanitization can be met. If co-mingling must be allowed to meet the requirements of the business need, the contractor must ensure that VA’s information is returned to the VA or destroyed in accordance with VA’s sanitization requirements. VA reserves the right to conduct onsite inspections of contractor and subcontractor IT resources to ensure data security controls, separation of data and job duties, and destruction/media sanitization procedures follow VA directive requirements.

c. Prior to termination or completion of this contract, contractor/subcontractor must not destroy information received from VA, or gathered/created by the contractor while performing this contract without prior written approval by the VA. Any data destruction done on behalf of VA by a contractor/subcontractor must be done in accordance with National Archives and Records Administration (NARA) requirements as outlined in VA Directive 6300, Records and Information Management and its Handbook 6300.1 Records Management Procedures, applicable VA Records Control Schedules, and VA Handbook 6500.1, Electronic Media Sanitization. Self-certification by the contractor that the data destruction requirements above have been met must be sent to the VA Contracting Officer within 30 days of termination of the contract.

d. The contractor/subcontractor must receive, gather, store, back up, maintain, use, disclose and dispose of VA information only in compliance with the terms of the contract and applicable Federal and VA information confidentiality and security laws, regulations, and policies. If Federal or VA information confidentiality and security laws, regulations and policies become applicable to the VA information or information systems after execution of the contract, or if NIST issues or updates applicable FIPS or Special Publications (SP) after execution of this contract, the parties agree to negotiate in good faith to implement the information confidentiality and security laws, regulations, and policies in this contract.

e. The contractor/subcontractor shall not make copies of VA information except as authorized and necessary to perform the terms of the agreement or to preserve electronic information stored on contractor/subcontractor electronic storage media for restoration in case any electronic equipment or data used by the contractor/subcontractor needs to be restored to an operating state. If copies are made for restoration purposes, after the restoration is complete, the copies must be appropriately destroyed.

f. If VA determines that the contractor has violated any of the information confidentiality, privacy, and security provisions of the contract, it shall be sufficient grounds for VA to withhold payment to the contractor or third party or terminate the contract for default or terminate for cause under Federal Acquisition Regulation (FAR) part 12.

g. If a VHA contract is terminated for cause, the associated BAA must also be terminated and appropriate actions taken in accordance with VHA Handbook 1600.01, Business Associate Agreements. Absent an agreement to use or disclose protected health information, there is no business associate relationship.

h. The contractor/subcontractor must store, transport, or transmit VA sensitive information in an encrypted form, using VA-approved encryption tools that are, at a minimum, FIPS 140-2 validated.

j. Except for uses and disclosures of VA information authorized by this contract for performance of the contract, the contractor/subcontractor may use and disclose VA information only in two other situations: (i) in response to a qualifying order of a court of competent jurisdiction, or (ii) with VA’s prior written approval. The contractor/subcontractor must refer all requests for, demands for production of, or inquiries about, VA information and information systems to the VA contracting officer for response.

Notwithstanding the provision above, the contractor/subcontractor shall not release VA records protected by Title 38 U.S.C. 5705, confidentiality of medical quality assurance records and/or Title 38 U.S.C. 7332, confidentiality of certain health records pertaining to drug addiction, sickle cell anemia, alcoholism or alcohol abuse, or infection with human immunodeficiency virus. If the contractor/subcontractor is in receipt of a court order or other requests for the above-mentioned information, that contractor/subcontractor shall immediately refer such court orders or other requests to the VA contracting officer for response. For service that involves the storage, generating, transmitting, or exchanging of VA sensitive information but does not require C&A or an MOU-ISA for system interconnection, the contractor/subcontractor must complete a Contractor Security Control Assessment (CSCA) on a yearly basis and provide it to the COR.

4. SECURITY INCIDENT INVESTIGATION

a. The term “security incident” means an event that has, or could have, resulted in unauthorized access to, loss or damage to VA assets, or sensitive information, or an action that breaches VA security procedures. The contractor/subcontractor shall immediately notify the COR and simultaneously, the designated ISO and Privacy Officer for the contract of any known or suspected security/privacy incidents, or any unauthorized disclosure of sensitive information, including that contained in system(s) to which the contractor/subcontractor has access.

b. To the extent known by the contractor/subcontractor, the contractor/subcontractor’s notice to VA shall identify the information involved, the circumstances surrounding the incident (including to whom, how, when, and where the VA information or assets were placed at risk or compromised), and any other information that the contractor/subcontractor considers relevant.

c. With respect to unsecured protected health information, the business associate is deemed to have discovered a data breach when the business associate knew or should have known of a breach of such information. Upon discovery, the business associate must notify the covered entity of the breach. Notifications need to be made in accordance with the executed business associate agreement.

d. In instances of theft or break-in or other criminal activity, the contractor/subcontractor must concurrently report the incident to the appropriate law enforcement entity (or entities) of jurisdiction, including the VA OIG and Security and Law Enforcement. The contractor, its employees, and its subcontractors and their employees shall cooperate with VA and any law enforcement authority responsible for the investigation and prosecution of any possible criminal law violation(s) associated with any incident. The contractor/subcontractor shall cooperate with VA in any civil litigation to recover VA information, obtain monetary or other compensation from a third party for damages arising from any incident, or obtain injunctive relief against any third party arising from, or related to, the incident.

5. LIQUIDATED DAMAGES FOR DATA BREACH

a. Consistent with the requirements of 38 U.S.C. §5725, a contract may require access to sensitive personal information. If so, the contractor is liable to VA for liquidated damages in the event of a data breach or privacy incident involving any SPI the contractor/subcontractor processes or maintains under this contract.

b. The contractor/subcontractor shall provide notice to VA of a “security incident” as set forth in the Security Incident Investigation section above. Upon such notification, VA must secure from a non-Department entity or the VA Office of Inspector General an independent risk analysis of the data breach to determine the level of risk associated with the data breach for the potential misuse of any sensitive personal information involved in the data breach. The term 'data breach' means the loss, theft, or other unauthorized access, or any access other than that incidental to the scope of employment, to data containing sensitive personal information, in electronic or printed form, that results in the potential compromise of the confidentiality or integrity of the data. Contractor shall fully cooperate with the entity performing the risk analysis. Failure to cooperate may be deemed a material breach and grounds for contract termination.

c. Each risk analysis shall address all relevant information concerning the data breach, including the following:

(1) Nature of the event (loss, theft, unauthorized access);

(2) Description of the event, including:

(a) date of occurrence.

(b) data elements involved, including any PII, such as full name, social security number, date of birth, home address, account number, disability code.

(3) Number of individuals affected or potentially affected.

(4) Names of individuals or groups affected or potentially affected.

(5) Ease of logical data access to the lost, stolen or improperly accessed data considering the degree of protection for the data, e.g., unencrypted, plain text.

(6) Amount of time the data has been out of VA control.

(7) The likelihood that the sensitive personal information will or has been compromised (made accessible to and usable by unauthorized persons).

(8) Known misuses of data containing sensitive personal information, if any.

(9) Assessment of the potential harm to the affected individuals.

(10) Data breach analysis as outlined in 6500.2 Handbook, Management of Security and Privacy Incidents, as appropriate: and

(11) Whether credit protection services may assist record subjects in avoiding or mitigating the results of identity theft based on the sensitive personal information that may have been compromised.

d. Based on the determinations of the independent risk analysis; the contractor shall be responsible for paying to the VA liquidated damages in the amount of $37.50 per affected individual to cover the cost of providing credit protection services to affected individuals consisting of the following:

(1) Notification.

(2) One year of credit monitoring services consisting of automatic daily monitoring of at least 3 relevant credit bureau reports.

(3) Data breach analysis.

(4) Fraud resolution services, including writing dispute letters, initiating fraud alerts and credit freezes, to assist affected individuals to bring matters to resolution.

(5) One year of identity theft insurance with $20,000.00 coverage at $0 deductible; and

(6) Necessary legal expenses the subjects may incur to repair falsified or damaged credit records, histories, or financial affairs.

6. SECURITY CONTROLS COMPLIANCE TESTING

On a periodic basis, VA, including the Office of Inspector General, reserves the right to evaluate any or all the security controls and privacy practices implemented by the contractor under the clauses contained within the contract. With 10 working-days’ notice, at the request of the government, the contractor must fully cooperate and assist in a government-sponsored security controls assessment at each location wherein VA information is processed or stored, or information systems are developed, operated, maintained, or used on behalf of VA, including those initiated by the Office of Inspector General. The government may conduct a security control assessment on shorter notice (to include unannounced assessments) as determined by VA in the event of a security incident or at any other time.

7. TRAINING

a. All contractor employees and subcontractor employees requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and its systems:

(1) Sign and acknowledge (either manually or electronically) understanding of and responsibilities for compliance with the Contractor Rules of Behavior, Appendix E relating to access to VA information and information systems.

(2) Successfully complete the VA Cyber Security Awareness and Rules of Behavior training and annually complete required security training.

(3) Successfully complete the appropriate VA privacy training and annually complete required privacy training; and

(4) Successfully complete any additional cyber security or privacy training, as required for VA personnel with equivalent information system access [to be defined by the VA program official and provided to the contracting officer for inclusion in the solicitation document – e.g., any role-based information security training required in accordance with NIST Special Publication 800-16, Information Technology Security Training Requirements.]

b. The contractor shall provide to the contracting officer and/or the COR a copy of the training certificates and certification of signing the Contractor Rules of Behavior for each applicable employee within 1 week of the initiation of the contract and annually thereafter, as required.

c. Failure to complete the mandatory annual training and sign the Rules of Behavior annually, within the timeframe required, is grounds for suspension or termination of all physical or electronic access privileges and removal from work on the contract until such time as the training and documents are complete.